Courts on AI / Fabricated or misquoted citations
Patrick C. Shaltry, I v. Brent Benzing, et al.
U.S. District Court for the Eastern District of Michigan · Federal district courts · MI · · No. 1:25-cv-13704 · order
On 2026-03-27, U.S. District Court for the Eastern District of Michigan warned the plaintiff that repeated false quotations and citations, including apparent AI hallucinations, would lead to sanctions for future violations. A self-represented party submitted an appellate brief with several false quotations and fabricated or nonexistent authorities, including People v. Swafford and People v. Kennedy.
- Disposition
- The court warned the plaintiff that repeated false quotations and citations, including apparent AI hallucinations, would lead to sanctions for future violations.
- Recorded conduct
- The appellate brief used several false quotations and fabricated or nonexistent authorities, including People v. Swafford and People v. Kennedy, which the court found nonexistent, misquoted, or unsupported. — outcome: warning; actor: litigant in person
- Canonical record
- Incident tracker entry — verified outcome, regulator disposition and related rules
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
final conviction and is presumed innocent while his appeal of right remains pending.” (E.g., ECF No. 31, PageID.620 (emphasis in original)). Because his appeal of right is still ongoing, Plaintiff contends that, as a matter of law, he has not been “convicted.” (Id.). In support, Plaintiff appears to quote several cases that, upon review, appear to be AI hallucinations. 2 (See ECF No. 29, PageID.605–06). For example, Plaintiff cites People v. Swafford, 762 N.W.2d 902, 904–05 (Mich. 2009), and attributes this quote to the case: “A conviction is not final until the completion of the direct appeal.” Although this case is real, the asserted quote is found nowhere within the case. The closest the cited case comes to Plaintiff’s proposition actually cuts the other way— that the defendant was convicted, notwithstanding that the conviction may later be overturned on appeal. See Id. at 905 n.5 (“Accordingly, the trial court did not have proper jurisdiction to bring defendant to trial or convict defendant.”). Thus, although AI “hallucinations” are instances where AI programs make stuff up. See Hunt v. Morissette, No. 24-cv-12947, 2025 WL 1660358, at *1 (E.D. Mich. June 11, 2025).